Response to EU Commission Sea Bass Proposals

We are campaigning for a range of measures to save the sea bass, which include:

Cutting 2016 landings to 541 tonnes, as recommended by the scientists.

Allocating fishing opportunities based on environmental and socio-economic criteria, as required by Article 17, Common Fisheries Policy.

Commercial and recreational fishing for bass to be restricted to rod & line and hand lines only. We believe this is the only possible way in which landings can be cut to 541 tonnes in 2016 whilst respecting Article 17.

A complete ban on commercial targeting of pre-spawning and spawning aggregations of bass.

All measures to be extended to the Bay of Biscay.

Moratorium from 1 January to 30 June

It would be better to restrict the fishery to recreational fishing and commercial fishing using rod & line and hand lines. A 6-month moratorium is a blunt tool that will have varying and arbitrary impacts on different stakeholders and does not allow for positive discrimination in favour of the fishing methods that deliver the highest environmental and socio-economic benefits to society.

We recognise that a moratorium is an extremely effective way of reducing fishing pressure on bass. If it is adopted, it must be accompanied by compensation to allow businesses dependent on sustainable bass fishing (recreational and commercial) to survive.

All measures must be extended to the Bay of Biscay to avoid displacement fishing.

2nd Half of 2016

We are not able to support the proposals for the 2nd half of 2016 for a number of reasons, including:

the stock level is now so dangerously low that we must follow the scientists’ advice immediately. The proposals target landings of 1,449 tonnes in 2016, an amount which is 2.7 times the 541 tonnes that the scientists have recommended.

the proposals do not appear to be applying Article 17. They should discriminate in favour of recreational angling and commercial rod & line and hand lines – which deliver the highest environmental and socio-economic benefits to society.

Again, all measures must be extended to the Bay of Biscay to avoid displacement fishing.

Saveourseabass.org and B.A.S.S. Response

Considerable confusion surrounds the sea bass proposals published by the EU Commission on Tuesday 10 November: the press release and the draft legislation are different! We understand that the draft legislation will be reissued shortly to include recreational fishing in the moratorium from 1 January to 30 June 2016, so that during that period it will also be prohibited for recreational fishermen to retain sea bass.

EU Commission also says that its proposals are not intended to prohibit catch & release bass fishing and that it is unlikely that any of the EU Member States will try to change this in the December negotiation.

Here are our thoughts on the proposals.

Bringing “the stock under MSY management by 2017”

The EU Commission has said that “The measures proposed build upon the measures already put in place in 2015, strengthening them to bring the stock under MSY management by 2017”

We are extremely pleased to hear that the EU Commission intends to start managing the bass fishery in line with the scientists’ advice with effect from 2017 (even though we would prefer it to be 2016).

“A complete fishing ban for commercial vessels and recreational anglers in the first half of 2016.”

Because of the dire state of the stock, it will sadly not be possible to achieve this goal without short-term pain for all stakeholders in the bass fishery. We need to bite the bullet now and take whatever measures are necessary to secure the stock for the future.

The scientists have estimated that in 2016 the spawning stock will be only 5,278 tonnes, which is only 28 tonnes greater than Blim, the level at which the stock size is so low that there is a high probability that recruitment will be impaired due to insufficient egg production (“recruitment” is the term used for young fish becoming mature and joining the spawning stock). The risk then, is that the stock fails to recover as expected and remains depleted for extended periods even when fishing is much reduced. To put these numbers into context, in 2010 – 2013 total bass landings were 5,667 tonnes per annum!

We do not agree with the EU Commission that a moratorium is the best approach. This is a blunt tool that will have varying and arbitrary impact on different stakeholders. Instead, we are campaigning for the fishery to be restricted to the fishing methods that deliver the highest environmental and socio-economic benefits to society: recreational fishing and commercial rod & line and hand line fishing. This would also be in line with Article 17 of the Common Fisheries Policy, which requires fishing opportunities to be allocated using “transparent and objective criteria including those of an environmental, social and economic nature.” We believe this is the only realistic way the bass fishery can now be managed sustainably.

We disagree with suggestions that all stakeholders should contribute on a “proportionate” basis. The words “proportionate and “fair” are typically used to mean that each stakeholder should take an equal share of the pain. This is not in line with the legal requirements of Article 17.

We recognise that a moratorium is an extremely effective way of reducing fishing pressure on bass. If it is adopted, it must be accompanied by compensation to allow businesses dependent on sustainable bass fishing (recreational and commercial) to survive.

Whatever measures are adopted, they must be extended to the Bay of Biscay to avoid displacement fishing.

We are deeply sceptical that there is sufficient scientific evidence to support the separate management of a “Southern” stock (i.e. Bay of Biscay: areas VIIIa and VIIIb) and the Northern stock. We note that:

the scientific research underpinning the recent MCRS increase was based on data for the whole of France, including the Bay of Biscay.

research in 2006 found that “Genetic results support no stock differentiation between Bay of Biscay and the English Channel” [1]

Artisanal fishermen in France have said: “Red Alert in the Bay of Biscay”. In the Bay of Biscay, there is a total absence of management measures, raising fears of an unprecedented intensification of effort. We are seeing once again the same catastrophic scenario that occurred in the North zone. Poor scientific evaluation resulting in an unacceptable status quo – it is because we do not yet have sufficient scientific knowledge that we must act! We ask urgently that management measures are put in place to regulate fishing for bass in the Bay of Biscay.” [2]

For commercial fishing vessels catching bass as by-catch, an allowance is proposed for bass to represent up to 1% of their total landings (the logic being that it is better for by-catch to be landed, recorded and taken into account, rather than simply being thrown back into the sea unrecorded). There is obviously a risk that this could give result in a significant level of bass landings. The EU Commission has assured us that it will monitor this closely.

“A monthly one tonne catch limit for vessels targeting sea bass, and a one fish bag limit for recreational anglers.” (to apply in the second half of 2016)

We believe that the current approach of trying to ratchet-down landings pari passu using vessel catch limits and bag limits cannot work. It is simply not possible to share only 541 tonnes of landings between all stakeholders.

Article 17 of the Common Fisheries Policy requires fishing opportunities to be allocated using “transparent and objective criteria including those of an environmental, social and economic nature.”

We believe that the only way of achieving landings of 541 tonnes and respecting Article 17 is by closing the bass fishery to all fishing except recreational angling and commercial rod & line and hand line fishing.

The EU Commission has stated that in these proposals it has attempted to treat recreational and commercial bass fishermen even-handedly. However, many recreational fishermen have expressed their concern that the proposals may favour commercial bass fishermen.

We initially tried to assess the impact of the proposals on the different stakeholders by using the UK monthly commercial landings data for 2014, but eventually realised that because the data is not representative of the true level of landings, any findings would have little or no basis in reality. The quality of landings data is a major issue across Europe and we are campaigning for changes to attain a fully documented bass fishery.

Given the poor quality of the data, we do not believe that the EU Commission is able to accurately estimate the impact of its proposals on the different stakeholders.

However, our analysis of reported UK bass landings for 2014 showed that, out of 1,331 vessels landing bass in 2014, only 227 vessels landed more than 1 tonne of bass in 2014 and only 111 vessels had at least one month where they landed more than 1 tonne of bass.

We are surprised by the 1 fish bag limit for recreational anglers. The scientists advised the EU Commission in December 2014 that an increase in the minimum landing size to 45cm and a 4 fish bag limit would reduce EU recreational landings by about 50% and encourage more compliance than a smaller bag limit. The combination of a one fish bag limit and 42cm minimum landing size is expected to cut EU recreational landings by between 52% and >64%.

The measures that we wish to see implemented:

A package of measures that will cut 2016 landings to 541 tonnes.[3]

Commercial and recreational fishing for bass to be restricted to rod & line and hand lines only.

A complete ban on commercial targeting of pre-spawning and spawning aggregations of bass.

A fully documented bass fishery, with all bass landings recorded.

A discard ban for bass from 2016.

A Long Term Management Plan that sets out clear management objectives, including an abundant stock and fishing opportunities allocated on socio-economic criteria.

[3] 541 tonnes is the maximum amount of landings recommended by the scientists for 2016, using the Maximum Sustainable Yield approach. NB We believe this approach to be fundamentally unsuited to a slow growing fish like bass that is highly dependent upon the strength of different year classes